Sanctions Desk

The recent outbreak of international conflicts has triggered an expansion of sanctions regimes, with a significant impact on the shipping industry.

Sanctions may target individuals and entities operating in the port and maritime sector, as well as vessels involved in illegal activities. They include import and export bans; restrictions on transport, insurance, and brokerage services; price limitations (e.g. oil price cap) and reporting requirements (e.g. for the sale of oil tankers) for trade of listed goods.

Sanctions compliance is not only of utmost importance for all maritime stakeholders, since a sanction breach can have significant legal, financial, and reputational consequences, but also a major challenge considering the constantly changing regulations.

Through this Sanctions Desk and thanks to our extensive expertise in shipping, we aim to assist our Clients in complying with the new regulations by providing regular updates and legal analysis on sanctions impacting the shipping industry. Our team is also available to advise maritime operators on the drafting of relevant clauses and to represent them in any disputes regarding sanctions.

20 March 2024
Deadline to insert the ‘No Russia’ clause in commercial contracts under the EU’s 12th package

From 20 March 2024, EU exporters must insert a so-called ‘No Russia’ clause in export/sale/supply/transfer or similar contracts concluded with customers based in third countries.

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This new obligation was introduced by the 12th package of sanctions against Russia adopted by the Council of the European Union on 18 December 2023.

The clause at stake should prohibit the re-export of specific sensitive goods to Russia and provide for ‘adequate remedies’ in the event of a breach, in order to hinder the circumvention of EU export bans and more especially the re-export of such goods to Russia.

In particular, Article 12g of the Council Regulation (EU) No 833/2014 -as amended- requires EU exporters that sell, supply, transfer or export goods or technology to a third country to contractually ban their customers from re-exporting certain sensitive goods to or for use in Russia. Such goods are those referred to in the following Annexes:

  • Annex XI (aviation and space items);

  • Annex XX (jet fuel and fuel additives);

  • Annex XXXV and Annex I to EU Regulation No. 258/2012  (firearms and ammunition); and

  • Annex XL (‘Common High Priority’ items).

The ‘No Russia’ clause must be included in contracts between EU exporters and their customers based in third countries. However, contracts concluded with customers based in partner countries –i.e. US, UK, South Korea, Australia, Canada, New Zealand, Norway, and Switzerland- do not need to be amended since these countries are considered as having effective sanctions enforcement regimes in place that prevent re-exports to Russia.

As to the timeframe of the applicability of the measure, the date of entry into force of the 12thpackage of sanctions, i.e.19 December 2023, is relevant; accordingly:

  • any contract concluded after 19 December 2023 must include a “No Russia” clause as of 20 March 2024;

  • any contract already concluded before 19 December 2023 benefits from a one-year transition period until 19 December 2024 included (or until the contract’s expiry, whichever is earliest).

In light of the above, EU exporters are required to draft a model of ‘No Russia’ clause to be included in all relevant contracts or, as an alternative, to give notice to all relevant counterparties that a ‘No Russia’ clause will be in effect from the applicable date. In view of the lack of any specification on the proper wording of the clause, the contractual parties are free to agree on their own appropriate wording as long as the clause meets the legal requirements. In this respect, it is worth noting that on 22 February 2024 the EU published a guidance on Article 12g requirement, which provides for a ‘No Russia’ clause template. It can be a useful starting point for the concerned business operators.


See our insight “12th Package of EU Sanctions against Russia: Impact on Shipping”

20 March 2024
23 February 2024
EU thirteenth package of sanctions against Russia

On 23 February 2024, the Council of the European Union adopted the 13th package of sanctions against Russia. Trade restrictions have been tightened: 27 additional entities - including companies located in China, India, Sri Lanka, Serbia, Kazakhstan, Thailand, and Turkey - blacklisted and export ban extended to drone components.


See our news “EU thirteenth package of sanctions against Russia”

23 February 2024
20 February 2024
Price cap mechanism: entry into force of new compliance requirements

New compliance requirements – introduced by the 12th package of sanctions and aiming at further implementing the price cap mechanism – are coming into force today. For Russian oil or petroleum products loaded on or after 20 February 2024, shipowners, ship management companies, insurers and insurance brokers shall:

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  • obtain per-voyage customer attestations in which the customer commits not to purchase Russian oil and petroleum products above the price cap;

  • require their counterparties to share information on itemised ancillary costs (e.g. insurance and freight) upon request and be able to share such information to the competent authorities or other counterparties if required. The EU Commission suggested to embed such requirement in relevant contracts, for example incorporating an ‘access to records’ clause which would be activated if the actor needed to seek information about a particular voyage.

Council Regulation (EU) 2023/2878 of 18 December 2023 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine


See our news “New compliance requirements with the price cap mechanism entering into force on February 20, 2024”

20 February 2024
18 December 2023
EU twelfth package of sanctions against Russia

The EU adopted the 12th package of sanctions against Russia, which imposes additional import and export bans (e.g. on diamonds and dual-use/industrial goods) and aims at combating sanctions circumvention and close loopholes, notably as a response to Russia’s endeavors to evade the oil price cap.

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The measures of particular relevance for the shipping industry are the following:

  • enforcement of oil price cap through:

    • the collection by services providers of itemized price information for ancillary costs throughout the supply chain of Russian crude oil (as of 20 February 2024);

    • the obligation to immediately notify any sale of tankers for the transport of Russian crude oil to third countries;

    • the obligation to obtain prior authorization to sell tankers to Russian persons and entities;

    • the strengthening of bilateral and multilateral cooperation to impede sanctions’ circumvention.

  • obligation for EU exporters to contractually prohibit re-exportation to Russia or for use in Russia of certain goods (i.e. no-Russia clause, to be included in commercial contracts from 20 March 2024). 

Council Regulation (EU) 2023/2878 of 18 December 2023 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine


See our insight “12th Package of EU Sanctions against Russia: Impact on Shipping”

18 December 2023
23 June 2023
EU eleventh package of sanctions against Russia

The Council adopted new restrictive measures against Russia. The agreed package includes amongst others, measures to:

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  • strengthen bilateral and multilateral cooperation with third countries to impede sanctions’ circumvention;
  • prohibit the transit of goods and technology via Russia;
  • tighten export restrictions.

The following restrictions are particularly relevant for the maritime sector:

  • prohibition to provide access to ports and locks in the EU territory by any vessel performing ship-to-ship transfers during the voyage to the EU port, if the competent authorities have reasonable grounds to suspect that the vessel is in breach of the prohibitions on the transport of Russian oil;
  • prohibition to grant access to ports and locks in the EU territory if a vessel does not notify the competent authority at least 48 hours in advance about a ship-to-ship transfer occurring withing the Exclusive Economic Zone of a Member State or within 12 nautical miles from the baseline of that Member State’s coast;
  • prohibition to provide access to ports and locks in the EU territory by any vessel which the competent authority has reasonable cause to suspect of illegally interfering with, switching off or otherwise disabling its AIS when transporting Russian crude oil and petroleum products.

Moreover, the EU decided that the sale or supply of cruise ships, ferryboats and other vessels for the transport of goods and/or persons, as well as the related technical or financial assistance, to a Russian entity or for use in Russia may exceptionally be authorized under specific conditions. 

Regarding individual restrictive measures, it shall be outlined that the scope of natural and legal persons targeted by sanctions has been extended to include those facilitating the infringements of the prohibition against circumvention of economic sanctions.

Finally, the Council clarified that the prohibition to make economic resources available to sanctioned parties does not apply to funds that are needed for the provision of pilot services to vessels in innocent passage.

Official Journal of the EU, 23 June 2023

23 June 2023
25 February 2023
EU tenth package of sanctions against Russia

The EU adopted the 10th package of economic and individual sanctions against Russia, which includes in particular:

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  • restrictions on additional critical technology and industrial goods on import (e.g. asphalt and synthetic rubber) and export (e.g. specialised vehicles, machine parts, spare parts for trucks, jet engines, etc.);
  • restriction on the possibility of Russian nationals to hold management positions in the governing bodies of EU critical infrastructure (i.e. infrastructure located in Member States which disruption or destruction would have a significant impact on at least two Member States);
  • prohibition to provide gas storage capacity (with the exclusion of the part of LNG facilities) to Russian nationals.

In addition, the Council clarified that the prohibitions on providing technical assistance laid down in Regulation (EU) No 833/2014 shall not apply to the provision of pilot services to vessels in innocent passage.

Finally, customs authorities have been authorized to released sanctioned goods physically in the EU and presented to customs prior to 26 February 2023.

Official Journal of the EU, 25 February 2023

25 February 2023
4 February 2023
EU agrees on further price caps for seaborne Russian petroleum products

EU agrees on further price caps for seaborne Russian petroleum products.
On top of the price cap for crude oil in force since December 2022, the Council decided to set two price caps for petroleum products (CN code 2710) which originate in or are exported from Russia:

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  • for “premium-to-crude” petroleum products (e.g. diesel, kerosene, gasoline), a maximum price of $100 per barrel;
  • for “discount-to-crude” petroleum products (e.g. fuel oil, napthta), a maximum price of $45 per barrel. 

These price caps will be implemented from 5 February 2023, including a 55-day wind-down period for seaborne Russian petroleum products purchased above the price caps, provided it is loaded onto a vessel at the port of loading prior to 5 February 2023 and unloaded at the final port of destination prior to 1 April 2023.

Official Journal of the EU, 4 February 2023

4 February 2023
16 December 2022
EU ninth package of sanctions against Russia

In response to Russia’s continuing war of aggression against Ukraine, the EU adopted a 9th package of sanctions, which includes bans on:

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  • exports of drone engines, dual-use goods and technology;
  • investment in the mining sector;
  • transactions with the Russian Regional Development Bank;
  • the provision of advertising, market research and public opinion polling services. 

In addition to economic sanctions, the Council decided to adopt a comprehensive package of individual measures listing a very significant number of additional individuals and entities.

Official Journal of the EU, 16 December 2022

16 December 2022
3 December 2022
EU agrees on an oil price cap

The Council decided to set a price cap for the transport of crude oil and petroleum oils and oils obtained from bituminous minerals (CN code 2709 00) which originate in or are exported from Russia. 

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As of 5 December 2022, the transport of Russian oil to third countries (and related insurance) is allowed provided that the oil was purchased at a price of $60 per barrel or less. This measure does not affect the transport of Russian oil to the EU, which, as a rule, is prohibited.

The EU made clear that shipping, freight, customs, and insurance costs were not included in the price cap and must be invoiced separately at commercially reasonable rates.

A transition period of 45 days has been foreseen for vessels carrying crude oil originating in Russia which was purchased and loaded on board prior to 5 December 2022 and unloaded at the final port of destination prior to 19 January 2023.

The Council also introduced an “emergency clause” which allows the transport of oil beyond the price cap to third countries if such transport is necessary for humanitarian or environmental purposes. 

Official Journal of the EU, 3 December 2022


See our insight “Price cap on Russian oil- Obligations of the maritime operators” 

3 December 2022
6 October 2022
EU eighth package of sanctions against Russia

Among the most relevant measures introduced by the 8th package of sanctions against Russia in the legal and maritime sector are:

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  • the prohibition for EU vessels to transport to third countries crude oil (as of December 2022) and other petroleum products (as of February 2023) which originate in or are exported from Russia, with possible exemptions based on price caps; 
  • the prohibition for EU nationals to hold any posts on the governing bodies of certain Russian state-owned or controlled legal persons, entities or bodies;
  • the prohibition to provide legal services (mostly extrajudicial) to legal persons and entities established in Russia, but with numerous exceptions (see amendments to art. 5n).

In addition, the Council decided to add to the list of state-owned entities that are subject to the transaction ban the Russian Maritime Register of Shipping. Such addition prohibits the provision of any sort of economically valuable benefit to the Russian Maritime of Shipping. 

Official Journal of the EU, 6 October 2022


See our insight “Eighth Package of EU Sanctions against Russia: Impact on Shipping” 

6 October 2022
21 July 2022
EU seventh package of sanctions against Russia

The Council adopted a further package of restrictive measures to tighten existing economic sanctions against Russia and strengthen their effectiveness. The most relevant measures introduced by the 7th package for the maritime sector are the following:

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  • the prohibition to provide access to EU ports to vessels flying the Russian flag has been extended to locks from 29 July 2022, with the exception of access to locks for the purpose of leaving the EU territory (see amendments to art. 3ea).
  • the exemption to the general prohibition to engage in transactions with listed companies (such as Rosneft, Transneft, Gazprom Neft, etc.) has been extended in order to cover transactions which are strictly necessary for the export of oil from or through Russia to third countries (and not only to the EU) (see amendments to art. 5aa).
  • the exemption to the general prohibition to engage in transactions with listed companies has been extended to transactions which are strictly necessary for the export of pharmaceutical and agricultural products from Russia to the EU/third countries.

Official Journal of the EU, 21 July 2022


See our insight “7th round of EU sanctions against Russia”

21 July 2022
3 June 2022
EU sixth package of sanctions against Russia

The EU decided to adopt a 6th package of economic and individual sanctions targeting both Russia and Belarus. The economic sanctions particularly relevant for the maritime sector are the following:

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  • a prohibition on the purchase, import or transfer into the EU of crude oil and petroleum products originating in or exported from Russia and on the insurance and reinsurance of maritime transport of such goods to third countries (with limited exemption such as imports by pipeline) (see art. 3m).
  • a prohibition to provide a series of services (e.g. technical/financial assistance, brokering services, insurance) related to the transport (including transshipment) of Russian crude oil and petroleum products to third countries (see art. 3n).

Among the individual sanctions, it is worth noting that three additional Russian banks and the Belarusian Bank for Development and Reconstruction were excluded from SWIFT. 

Official Journal of the EU, 3 June 2022


See our insight “Sixth round of EU sanctions: transport of oil by sea”

3 June 2022
8 April 2022
EU fifth package of sanctions against Russia

The EU adopted a fifth round of sanctions against Russia. To the prohibition to export goods and technologies suited for use in oil refining (in force since late February 2022), the Council added a ban on exporting those suited for liquefaction of natural gas. 

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Additional bans on the export of goods to or for use in Russia have been introduced, such as bans on:

  • exports of jet fuel and fuel additives;
  • exports of goods which could contribute in particular to the enhancement of Russian industrial capacities as listed in Annex XXIII to any natural or legal persons in Russia.

Regarding the import into the EU of goods originating in Russia or exported from Russia, the following prohibitions can be mentioned:

  • prohibition to import goods which generate significant revenues for Russia thereby enabling its actions destabilising the situation in Ukraine, as listed in Annex XXI, which includes among others cruise ships;
  • prohibition to import coal and other solid fossil fuels.

The provision of services related to the above-mentioned goods is also prohibited.

In addition, the Council introduced a ban on all Russian vessels from accessing the EU ports as well as a ban on Russian and Belarussian road transport operators from entering the EU. 

Finally, the EU also adopted sanctions against 217 individuals and 18 entities, including a full transaction ban on four key Russian banks, representing a 23% market share in the Russian banking sector.

Official Journal of the EU, 8 April 2022


See our insight “The fifth package of EU sanctions against Russia”

8 April 2022
15 March 2022
EU fourth package of sanctions against Russia

The EU imposed a fourth package of economic and individual sanctions, including the prohibition to:

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  • import, purchase, transport into the EU iron and steel products originating in Russia or exported from Russia;
  • sell, supply, transfer or export luxury goods to any natural or legal persons in Russia or for use in Russia;
  • engage in any transaction with certain state-owned enterprises as listed in Annex X, with the exemption of transactions which are strictly necessary for the import of fossil fuels and specific ore from Russia into the Union;
  • provide credit rating services, as well as access to any subscription services in relation to credit rating activities, to any Russian person or entity;
  • invest in the Russian energy sector.

The EU also introduced sanctions on additional 15 individuals and 9 entities, including companies in the aviation, military and dual use, shipbuilding and machine building sectors. 

Official Journal of the EU, 15 March 2022

15 March 2022
2 March 2022
EU third package of sanctions against Russia

The EU excluded from SWIFT seven Russian banks (Bank Otkritie, Novikombank, Promsvyazbank, Rossiya Bank, Sovcombank, Vnesheconombank (VEB), VTB Bank) and the ones they directly or indirectly own for more than 50%.

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The EU also introduced a ban on:

  • investing, participating or otherwise contributing to future projects co-financed by the Russian Direct Investment Fund.
  • selling, supplying, transferring or exporting euro banknotes to Russia or to any natural or legal person or entity in Russia.

Council Regulation (EU) 2022/345 of 1 March 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine

2 March 2022
28 February 2022
EU third package of sanctions against Russia
28 February 2022
25 February 2022
EU second package of sanctions against Russia

The EU agreed on further individual and economic measures, among which:

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  • the prohibition to sell, supply, transfer or export, directly or indirectly, to any natural or legal person, entity or body in Russia or for use in Russia, the following goods:
    • “dual-use” goods and technologies (which are defined in: link);
    • goods and technologies which might contribute to Russia’s military and technological enhancement, or the development of the defence and security sector, as listed in Annex VII;
    • goods and technologies suited for use in oil refining, as listed in Annex X;
    • goods and technologies suited for use in aviation or the space industry, as listed in Annex XI.

  • It shall be noted that the prohibition applies whether or not the goods are originating in the EU and that the provision of services related to the above-mentioned goods is also prohibited. 

  • restrictions on financial activities

Council Regulation (EU) 2022/328 of 25 February 2022 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine

25 February 2022
23 February 2022
EU first package of sanctions against Russia

The Council of the European Union adopted a package of measures in response to Russian’s invasion of Ukraine. The agreed package includes:

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  • targeted sanctions against the 351 members of the Russian State Duma and an additional 27 individuals;
  • restrictions on economic relations with the non-government controlled areas of Donetsk and Luhansk oblasts;
  • restrictions on Russia's access the EU’s capital and financial markets and services. 

Official Journal of the EU, 23 February 2022

23 February 2022

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